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Comment 58 for Public Comments for LCFS pathway applications (tier2lcfspathways-ws) - 2nd Workshop.


First Name: Ranji
Last Name: George
Email Address: h2zevforum@gmail.com
Affiliation:

Subject: LCFS regulation
Comment:
To ARB Governing Board, management and staff

Please consider providing LCF credits to the electricity needed to
liquefy dispensed hydrogen fuel.  Since its so intimately involved
with increasing the hydrogen ZEV range, and is actually dispensed,
ARB should give at least partial LCF credits to facilitate liquid
H2 fueling. It is a fundamental part of emerging H2 fueling
infrastructure.

In general, even though ARB and CEC have expressed itself to be
neutral to ZEV funding stating that either battery EVs and Hydrogen
EVs can qualify - 80
percent of the state funding since year 2000 have gone towards
batteries.  That is for every $1 of funding in hydrogen ZEVs, about
4 times  have gone to battery ZEVs.

 In total, according to San Diego Tribune
(or Union?), the total ZEV incentives have been 2.5 billion. What
it fails to notice, how hydrogen ZEVs got only a small fraction. 
Because of this sustained funding, battery ZEVs are now way ahead
of hydrogen ZEVs.  This is inconsistent with "neutrality".

Hydrogen ZEVs have numerous benefits - including longer range,
faster recharging, and none of the toxic chemicals inherent in
battery packs. The latter chemicals are mined in disadvantaged
areas in the world, and then ultimately will be recycled in such
areas within USA or abroad.  Hydrogen ZEVs avoid that.

So please make up for the lack of funding for Hydrogen ZEVs by
increasing dramatically the focus on the hydrogen fueling.

California is recognized as the world leader in both technologies.
Within California, it was the author (in the early 90s) as the lead
scientist at SCAQMD - regional air quality agency in Southern
California - that started California's movement towards battery 
EVs, and later hydrogen EVs.  We launched and treated both ZEV
technologies fairly - but unfortunately ARB has shown sustained
bias.  Please correct this bias.



Yours truly
Ranji George










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Date and Time Comment Was Submitted: 2020-11-24 16:47:03



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